Israel - Dividend

Article 11. Dividends

1. Dividends paid by a company which is a resident of one of the States to a resident of the other State may be taxed in that other
State.

2. However, such dividends may be taxed in the State of which the company paying the dividends is a resident, and according to the
laws of that State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed:

a) with respect to dividends paid by a company which is a resident of one of the States to a company the capital of which is wholly
or partly divided into shares and which is a resident of the other State and holds directly at least 25 per cent of the capital of the
company paying the dividends:

i 10 per cent of the gross amount of the dividends where the dividends are paid out of profits which, by virtue of provisions in Israeli
law for the encouragement of investment in Israel, are exempted from tax or subject to tax at a rate that is lower than the standard
rate levied on the profits of a company resident in Israel;

ii 5 per cent of the gross amount of the dividends in other cases;

b) 15 per cent of the gross amount of the dividends in all other cases.

3. The competent authorities of the States shall by mutual agreement settle the mode of application of paragraph 2.

4. The provisions of paragraph 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are
paid.

5. The term “dividends” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares,
founders'shares or other rights participating in profits as well as income from debt-claims participating in profits and income from
other corporate rights assimilated to income from shares by the taxation law of the State of winch the company making the
distribution is a resident.

6. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the dividends, being a resident of one of the States, has in
the other State. of which the company paying the dividends is a resident, a permanent establishment with which the holding by virtue
of which the dividends are paid is effectively connected. In such a case, the provisions of Article 8 shall apply.

7. Where a company which is a resident of one of the States derives profits or income from the other State, that other State may not
impose any tax on the dividends paid by the company to persons who are not residents of that other State. or subject the company's
undistributed profits to a tax on undistributed profits, even if the dividends paid on the undistributed profits consist wholly or partly of
profits or income arising in such other State.

Protocol:

III Ad Articles 11, 12 and 13

Applications for the restitution of tax levied contrary to the provisions of Articles 11, 12 and 13 to be lodged with the competent
authority of the State having levied the tax within a period of 5 years after the expiration of the calendar year in which the tax has
been levied.

IV Ad Article 11

With reference to paragraph 2 of Article 11 of the Convention, the two Governments, having in mind that the difference between the
provisions of sub-paragraph a) and those of sub-paragraph b) of the said paragraph is based on the fact that in Israel the tax burden in
the hands of Israeli companies for distributed profits is substantially lower than that for undistributed profits, agree to undertake the
review of the said provisions in order to adapt sub-paragraph b) to sub-paragraph a) when the basis of such difference no longer
exists.